Challenge to Section 68 Reassessment: Lack of Concrete Evidence Invalidates Assessing Officer's Belief u/ss 147/148.

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....Reopening of assessment - addition u/s 68 - there is absence of link between alleged tangible material and formation of belief. At the most, it could be inferred that the belief of the A.O. was based on mere imagination, speculation and suspicion - it is not a fit case for initiation of reassessment proceedings under section 147/148.....